Conclusions ‘not supported by any scientific investigation


‘A submission by the Government agency Inland Fisheries Ireland will slam the proposed Galway Bay Fish Farm. The application for the 15,000 ton salmon farm – which would be the biggest in Europe – is being made by the semi–state agency who will then franchise the licensce to the highest bidder.


The ‘Submission by Inland Fisheries Ireland on the Environmental Impact Statement for a Deep Sea Fish Farm Development in Galway’ is available from the IFI website. It is highly critical of the Environmental Impact Statement [EIS].The submission alleges that the EIS contains many statements ‘not supported’ by research and that some relevant research is noticeably absent – such as data gathered  at the proposed site by the Celtic Voyager.


IFI points out, for example, that ‘no data is provided on the known migration routes of salmonids’ to support BIM’s claim that there is a ‘very low to zero risk of farmed salmon sea lice infecting wild salmon’, that ‘the extensive literature published on interactions of sea trout and salmon lice in Ireland are not referred to or discussed’, and that the sea lice issue is ‘a legitimate concern in this proposal’.


The submission states that in the EIS ‘Presumptions are made and conclusions drawn regarding the potential impact of sea lice from the proposed locations on wild smolts which are not supported by any scientific investigation.’

It criticises the ‘tenuous mechanism to assist in invasive species control’ which may arise form the importation of smolts on this scale’.

It points out that the overwhelming research showing genetic modification of wild salmon are absent with the two papers referred to actually coming to the ‘opposite conclusion’ of that reported in the EIA. With ‘2.5 million mature salmon present on site annually in autumn an escape would pose a significant threat for interbreeding with the wild salmon stock’.

The submission concludes that ‘A full monitoring system should be put in place and a baseline study undertaken in advance of any farm being established’.
In an unprecedented move, a special consultation period was set for statutory consultees in advance of the public consultation ‘as directed by the Department of Agriculture Food and Marine to further assist in the public’s assessment of the Environmental Impact Statement’.

However BIM has not included the submission on their website with the other consultees because it was received on 3 October, 2012. The statutory consultation period closed on 2 October, 2012.

IFI states that a delay was caused by the BIM delay in providing extra copies requested by the organisation. A spokesman for Friends of the Irish Environment said that the failure to make the EIS available electronically – as has now been done for the public consultation – is an infringement of the Access to Information on the Environment regulations.

The submission will be made during the current public consultation period, which ends on 12 December, 2012 but BIM claims it is under no obligation to make the submission available with the other statutory consultees as it was received after the deadline.

Inland Fisheries Ireland submission on its website

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